# Can my client hold it? Who may hold every tokenized program on file

> The answer turns on two facts about the client: investor status and the kind of account. Each program’s issuer sets both in writing, and most programs on file are closed to an ordinary US household.

- URL: https://riadefi.com/tokenized-assets/who-may-hold/
- Section: Asset classes
- Author: Jon Ragsdale
- Reviewed: 2026-09-30

Reader objective: Find, for one client, which tokenized programs the issuer’s own terms allow them to hold, and in which account.

## The answer, counted

Of the 95 tokenized programs Ketju has on file, **an ordinary US client who is not accredited may buy 35.** Accredited status opens 9 more, and qualified-purchaser status 12 more. 39 are closed to every US person, whatever the client’s wealth. The retail group is smaller than it looks: 2 of its 35 programs ask $1 million or more for a first purchase, and 33 publish no list of the states where they sell. An IRA narrows the list again. 2 programs name IRAs as eligible holders, 4 exclude them in writing, and the other 89 do not say.

Each row below is read from the program’s eligibility file, which quotes the issuer’s documents and dates the reading. The freeze-key column is read from the chain, last read on 2026-09-30. The newest file was reviewed on 2026-09-30.

## Every program on file

Jump to: [US retail investors 35 ](#retail) [US accredited investors 9 ](#accredited) [US qualified purchasers 12 ](#qualified-purchasers) [Not offered to US persons 39 ](#not-us)

| Program | Kind | Who may hold | Minimum | IRAs and other accounts | Freeze key | Exit |
| --- | --- | --- | --- | --- | --- | --- |
| US retail investors · 35 programs |
| ARK Venture Fund (ARKVX), tokenized by Securitize | Mixed | US retail (states not published; broker-dealer onboards) | $500 | Names IRAs (also individuals) | A single key | Issuer redemption |
| BlackRock Daily Reinvestment Stablecoin Reserve Vehicle (RSVXX), BRSRV token | Money-market fund | US retail (states not published; issuer onboards) | $3,000,000 | Does not say (onboards individuals, entities, and financial intermediaries) | A single key | Fund redemption at NAV |
| BlackRock Select Treasury Based Liquidity Fund, OnChain Shares (DOLXX), BSTBL token | Money-market fund | US retail (states not published; issuer onboards) | $3,000,000 | Does not say (onboards institutions) | A single key | Fund redemption at NAV |
| CURRENC Group ordinary shares in token form (Securitize, on Solana, Avalanche and Ethereum) | Stock | US retail (states not published; issuer onboards) | Not stated | Does not say (no account types named) | A single key | Redeem in kind |
| DeedFlow Royalty Revenue Bonds, Series 2026 | Note | US retail (states not published; issuer onboards) | $2,500 | Does not say (onboards individuals and entities) | No contract to read | No exit stated |
| DGLD (Gold Token SA) | Commodity | US retail (states not published; no onboarding) | Not stated | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 1 other route) |
| Draggable Aktionariat AG Shares (DAKS: the issuer’s own registered shares as Swiss ledger-based securities on Ethereum) | Stock | US retail (states not published; no onboarding) | Not stated | Does not say | No freeze or claw-back power read | Market sale only (and 1 other route) |
| DTC Tokenization Service: tokenized security entitlements to DTC-held stocks, ETFs, and Treasuries | Mixed | US retail (states not published; broker-dealer onboards) | Not stated | Does not say | DTC’s root wallet; no contract is public yet | Exchange sale, T+1 |
| Exodus Movement Class A common stock tokens (Securitize on Algorand; Superstate on Solana) | Stock | US retail (all states; issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A single key | Redeem in kind |
| Figure Technology Solutions Series A Blockchain Common Stock (FGRS) | Stock | US retail (states not published; issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A power exists; its holder was not read | Redeem in kind (and 1 other route) |
| Figure YLDS (Figure Transferable Certificates) | Note | US retail (states not published; issuer onboards) | $0.01 | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| Finest fGLD | Commodity | US retail (states not published; issuer onboards) | Not stated | Does not say (onboards individuals and entities) | No freeze or claw-back power read | Redeem in kind (and 1 other route) |
| Franklin OnChain U.S. Government Money Fund (FOBXX), BENJI token | Money-market fund | US retail (states not published; issuer onboards) | $20 | Excludes IRAs (onboards individuals and institutions) | A single key | Fund redemption at NAV |
| GoldZip (XGZ) | Commodity | US retail (states not published; no onboarding) | Not stated | Does not say (onboards individuals and entities) | A contract | Redeem in kind (and 1 other route) |
| Herculis Gold Coin (XAUH) | Commodity | US retail (states not published; issuer onboards) | Not stated | Does not say (no account types named) | A 3-of-4 multisig | Redeem in kind (and 1 other route) |
| Kinesis gold on Ethereum (ERC-20 KAU, KMS Labs) | Commodity | US retail (states not published; no onboarding) | Not stated | Does not say | A single key | Redeem in kind |
| Kinesis silver on Ethereum (ERC-20 KAG, KMS Labs) | Commodity | US retail (states not published; no onboarding) | Not stated | Does not say | A single key | Redeem in kind |
| Lofty property shares (one Algorand asset per rental property) | Real estate | US retail (states not published; issuer onboards) | Not stated | Does not say (onboards individuals) | A contract run by a single key | Market sale only |
| Matrixdock Gold (XAUm) | Commodity | US retail (states not published; issuer onboards) | $10,000 | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 2 other routes) |
| Matrixdock Silver (XAGm) | Commodity | US retail (states not published; issuer onboards) | $10,000 | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 2 other routes) |
| Nomyx Revenue Participation Bonds, Series 2026 (Bond Tokens) | Note | US retail (states not published; issuer onboards) | $2,000 | Does not say (onboards individuals and entities) | No contract to read | No exit stated |
| PAX Gold (PAXG) | Commodity | US retail (states not published; issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 2 other routes) |
| Pleasing Gold (PGOLD) | Commodity | US retail (states not published; no onboarding) | Not stated | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 2 other routes) |
| SilverTimes Token (STT) | Commodity | US retail (states not published; issuer onboards) | Not stated | Does not say (no account types named) | A single key | Redeem in kind (and 1 other route) |
| STRATO Gold and Silver (GOLDST, SILVST) | Commodity | US retail (states not published; no onboarding) | Not stated | Does not say (onboards individuals and entities) | A contract | Redeem in kind (and 1 other route) |
| Superstate Opening Bell (tokenized common stock of listed companies) | Stock | US retail (states not published; issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 1 other route) |
| Switzerlend AG C1 Shares SHA (LENDS: preferred shares of the lend.ch lending platform as Swiss ledger-based securities, locked in a drag-along contract) | Stock | US retail (states not published; no onboarding) | Not stated | Does not say | No freeze or claw-back power read | Market sale only (and 1 other route) |
| Token Teknoloji Gram Gold and Gram Silver (GRAMG, GRAMS) | Commodity | US retail (states not published; issuer onboards) | Not stated | Does not say (onboards individuals) | A single key | Issuer redemption |
| Tokenized SECZ (Securitize Corp. common stock, issuer-tokenized on Avalanche and Solana) | Stock | US retail (states not published; broker-dealer onboards) | Not stated | Does not say (no account types named) | A single key | Redeem in kind (and 1 other route) |
| USDtb (Anchorage Digital Bank) | Payment stablecoin | US retail (states not published; no onboarding) | Not stated | Does not say (no account types named) | A single key | Issuer redemption (and 1 other route) |
| VNX Gold (VNXAU) | Commodity | US retail (states not published; issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 2 other routes) |
| wemakeit AG shares (WMKT: a Swiss crowdfunding platform’s registered shares as ledger-based securities on Ethereum) | Stock | US retail (states not published; no onboarding) | Not stated | Does not say | A contract | Market sale only |
| WisdomTree 500 Digital ETF | ETF | US retail (states not published; issuer onboards) | Not stated | Does not say | No contract to read | Redeem in kind |
| WisdomTree Treasury Money Market Digital Fund (WTGXX) | Money-market fund | US retail (50 states; distributor onboards) | $1 | Does not say (onboards individuals and entities) | A single key | Fund redemption at NAV |
| xU3O8 (uranium.io) | Commodity | US retail (states not published; no onboarding) | Not stated | Does not say (onboards individuals and entities) | A single key | Redeem in kind (and 1 other route) |
| US accredited investors · 9 programs |
| Apollo Diversified Credit Securitize Fund (ACRED) | Credit fund | Accredited (broker-dealer onboards) | $50,000 | Does not say (no account types named) | A single key | Issuer redemption |
| Blockchain Capital Token (BCAP) | Mixed | Accredited (issuer onboards) | Not stated | Does not say (no account types named) | A single key | No exit stated |
| BNY Dreyfus On-Chain Liquidity Fund (BCLXX), BLIQUID token | Money-market fund | Accredited (issuer onboards) | $3,000 | Excludes IRAs (onboards institutions and stablecoin issuers) | No contract to read | Fund redemption at NAV |
| Fidelity Treasury Digital Fund, OnChain class (FYOXX), FDIT token | Money-market fund | Accredited (issuer onboards) | $1,000,000 | Does not say (onboards institutions) | A power exists; its holder was not read | Fund redemption at NAV |
| OpenEden TBILL | Treasury fund | Accredited (issuer onboards) | $100,000 | Does not say (onboards individuals and entities) | A 3-of-4 multisig | Issuer redemption |
| OpenTrade Loan Vaults (XMMF, XTBT, XEVT, XFTB, XHYC) | Note | Accredited (issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| Securitize Tokenized AAA CLO Fund (STAC) | Credit fund | Accredited (broker-dealer onboards) | $100,000 | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| Streamex GLDY | Commodity | Accredited (issuer onboards) | $1 | Names IRAs (also individuals, entities, trusts, and benefit plans) | A power exists; its holder was not read | Issuer redemption (and 1 other route) |
| Tradable private-credit deal tokens | Note | Accredited (issuer onboards) | $5,000,000 | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| US qualified purchasers · 12 programs |
| Bitwise Crypto Carry Fund (USCC) | Mixed | Qualified purchasers (issuer onboards) | $100,000 | Excludes IRAs (onboards individuals and entities) | A single key | Fund redemption at NAV |
| BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I) | Treasury fund | Qualified purchasers (broker-dealer onboards) | $5,000,000 | Does not say (onboards entities) | A single key | Issuer redemption |
| Coinbase USD Stablecoin Yield Fund (CUSHY) | Credit fund | Qualified purchasers (issuer onboards) | $100,000 | Does not say | A single key | Issuer redemption |
| Delta Wellington Ultra Short Treasury On-Chain Fund (ULTRA) | Treasury fund | Qualified purchasers (issuer onboards) | $200,000 | Does not say | A single key | Issuer redemption |
| Franklin OnChain Institutional Liquidity Fund (iBENJI) | Money-market fund | Qualified purchasers (issuer onboards) | $5,000,000 | Does not say | A single key | Issuer redemption |
| Hamilton Lane Equity Opportunities Securitize Fund V (HLEOVUS) | Mixed | Qualified purchasers (broker-dealer onboards) | $20,000 | Does not say | A power exists; its holder was not read | No exit stated |
| Hamilton Lane Secondary VI Securitize Fund (HLSF6) | Mixed | Qualified purchasers (broker-dealer onboards) | $20,000 | Does not say | A power exists; its holder was not read | No exit stated |
| Hamilton Lane Senior Credit Opportunities Securitize Fund (HLSCOPE) | Credit fund | Qualified purchasers (broker-dealer onboards) | $10,000 | Does not say | A single key | Issuer redemption |
| Invesco Short Duration US Government Securities Fund (USTB) | Treasury fund | Qualified purchasers (issuer onboards) | $100,000 | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| Neuberger Securitize High Income Tokenized Fund (HINC) | Credit fund | Qualified purchasers (broker-dealer onboards) | $100,000 | Does not say (onboards entities) | A single key | Issuer redemption |
| Ondo Short-Term U.S. Government Treasuries (OUSG) | Treasury fund | Qualified purchasers (issuer onboards) | $5,000 | Does not say (onboards individuals and entities) | An account only a program can sign for | Issuer redemption |
| VanEck Treasury Fund (VBILL) | Treasury fund | Qualified purchasers (broker-dealer onboards) | $1,000,000 | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| Not offered to US persons · 39 programs |
| Anchored aStocks (trust receipts by Anchored Capital Ltd, BVI, over Anchored Finance SPC fund shares; "a" tickers) | Mixed | Not US persons (issuer onboards) | $100,000 | Does not say (onboards individual professional investors and entities (institutions, corporations, trusts)) | No freeze or claw-back power read | Issuer redemption (and 1 other route) |
| Anemoy Tokenized Apollo Diversified Credit Fund (ACRDX) | Credit fund | Not US persons (issuer onboards) | $500,000 | Does not say (no account types named) | A contract | Issuer redemption |
| Backpack Securities stock tokens (trust receipts by Trek Nexus Markets Ltd, BVI, on Solana) | Mixed | Not US persons (distributor onboards) | $1 | Does not say | An account only a program can sign for | Redeem in kind (and 1 other route) |
| bStocks (certificates by BTech Holdings Ltd, a Binance group company, "B" tickers) | Mixed | Not US persons (distributor onboards) | Not stated | Does not say | A power exists; its holder was not read | Redeem in kind (and 1 other route) |
| bTokens (tracker certificates by Backed Assets (JE) Limited, "b" tickers, winding down) | Mixed | Not US persons (issuer onboards) | $6,076 | Does not say (onboards individuals and entities) | A single key | Issuer redemption (and 1 other route) |
| Circle USYC | Treasury fund | Not US persons (issuer onboards) | $100,000 | Excludes IRAs (onboards entities) | A single key | Issuer redemption |
| Coinbase Tokenized Stock (certificates by Coinbase Onchain SPV Ltd, ADGM, "c" tickers on Base) | Stock | Not US persons (issuer onboards) | Not stated | Does not say | A single key | Redeem in kind (and 1 other route) |
| deJAAA (Open Market Factory notes linked to JAAA) | Note | Not US persons (issuer onboards) | $10,000 | Does not say (onboards individuals and entities) | A contract | Issuer redemption (and 1 other route) |
| DigiFT security tokens (iSNR, bEQTY, pEAK, CMBMINT and others) | Mixed | Not US persons (distributor onboards) | Not stated | Does not say (onboards individuals and companies) | A power exists; its holder was not read | Issuer redemption |
| Dinari dShares (tokenized US stocks and ETFs) | Mixed | Not US persons (distributor onboards) | Not stated | Does not say (onboards individuals, entities, distributors, and aggregators) | A contract run by a single key | Issuer redemption |
| Dominion Silver (SILV) | Commodity | Not US persons (issuer onboards) | Not stated | Does not say (onboards individuals and entities) | An account only a program can sign for | Issuer redemption (and 2 other routes) |
| Etherfuse Stablebonds (credit claims on sovereign bonds bought through Mexican brokers: CETES, USTRY, TESOURO, KTB, GILTS, EUROB) | Note | Not US persons (issuer onboards) | Not stated | Does not say | A 3-of-5 multisig | Fund redemption at NAV (and 1 other route) |
| Fidelity International USD Digital Liquidity Fund (FILQ-A, FILQ-D) | Money-market fund | Not US persons (distributor onboards) | $100,000 | Does not say (onboards professional investors) | A power exists; its holder was not read | Issuer redemption |
| Hamco Tokenized Pan-Asia Private Equity Fund | Mixed | Not US persons (distributor onboards) | Not stated | Does not say (no account types named) | No contract to read | Issuer redemption |
| Janus Henderson Anemoy AAA CLO Fund (JAAA) | Credit fund | Not US persons (issuer onboards) | $500,000 | Does not say (onboards individuals and entities) | A contract | Issuer redemption |
| Janus Henderson Anemoy Treasury Fund (JTRSY) | Treasury fund | Not US persons (issuer onboards) | $500,000 | Does not say (onboards individuals and entities) | A contract | Issuer redemption |
| Midas mTBILL | Note | Not US persons (issuer onboards) | $1 | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| Obligate Trade Finance Yield (oTFY) | Note | Not US persons (issuer onboards) | $100,000 | Does not say | A single key | Issuer redemption (and 1 other route) |
| Ondo Global Markets (tokenized stocks and ETFs, "on" tickers) | Note | Not US persons (issuer onboards) | $1 | Does not say (onboards entities) | An account only a program can sign for | Issuer redemption (and 2 other routes) |
| Ondo Intelligent Portfolios (seven portfolio tokens, "on" tickers) | Note | Not US persons (issuer onboards) | Not stated | Does not say (onboards entities) | A 4-of-7 multisig | Issuer redemption (and 1 other route) |
| Ondo U.S. Dollar Yield (USDY, rUSDY, mUSD) | Note | Not US persons (issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A single key | Issuer redemption |
| OnRe Tokenized Reinsurance (ONyc) | Mixed | Not US persons (issuer onboards) | Not stated | Does not say | An account only a program can sign for | Issuer redemption (and 1 other route) |
| RealT RealTokens (per-property rental interests, in liquidation) | Real estate | Not US persons (issuer onboards) | $50 | Does not say (onboards individuals and entities) | A single key | No exit stated |
| RealUnit Shares (REALU: RealUnit Schweiz AG’s registered shares as Swiss ledger-based securities on Ethereum) | Stock | Not US persons (no onboarding) | Not stated | Does not say | A contract | Market sale only |
| Republic pre-IPO notes on Bitget IPO Prime (preOPAI, preSPCX) | Note | Not US persons (distributor onboards) | $100 | Does not say | An account only a program can sign for | Issuer redemption (and 1 other route) |
| Robinhood Stock Tokens (tracker certificates by Robinhood Assets (Jersey) Limited on Robinhood Chain) | Note | Not US persons (distributor onboards) | None | Does not say (onboards individuals and entities) | A single key | Market sale only (and 1 other route) |
| rTokens (Reality, Bitget’s issuance platform; listed on CoinGecko as "rStock") | Note | Not US persons (issuer onboards) | Not stated | Does not say | A power exists; its holder was not read | Issuer redemption (and 1 other route) |
| Spiko Digital Assets Cash and Carry Fund (SPKCC, eurSPKCC) | Note | Not US persons (issuer onboards) | $114,110 | Does not say (onboards individuals and entities) | A contract run by a single key | Fund redemption at NAV |
| Spiko SICAV: US T-Bills, EU T-Bills, and Amundi Overnight Swap Funds (USTBL, EUTBL, SAFO) | Mixed | Not US persons (issuer onboards) | $1 | Does not say (onboards individuals and entities) | A contract run by a single key | Fund redemption at NAV |
| ST0x tokenized stocks and ETFs (S01 Issuer GmbH debt tokens on Base; traded as wt- vault shares) | Mixed | Not US persons (no onboarding) | $1 | Does not say (onboards individuals and entities) | A 3-of-6 multisig | Market sale only (and 1 other route) |
| Sygnum FIUSD (Fidelity Institutional Liquidity Fund, US Dollar Fund, Class G Acc) | Money-market fund | Not US persons (issuer onboards) | None | Does not say (onboards professional investors) | A power exists; its holder was not read | Issuer redemption |
| Tenbin Gold (tGLD) | Note | Not US persons (issuer onboards) | Not stated | Does not say (onboards individuals and entities) | A 3-of-5 multisig | Issuer redemption (and 1 other route) |
| Tessera T-Tokens (loans to Panama issuers repaid from SpaceX, Kalshi, and OpenAI exposure) | Note | Not US persons (no onboarding) | Not stated | Does not say | A single key | Issuer redemption (and 1 other route) |
| Tether Gold (XAUT) | Commodity | Not US persons (issuer onboards) | Not stated | Does not say | A 3-of-6 multisig | Redeem in kind |
| Theo Short Duration US Treasury Fund (thBILL) | Treasury fund | Not US persons (issuer onboards) | Not stated | Does not say (no account types named) | A single key | Issuer redemption (and 1 other route) |
| UBS USD Money Market Investment Fund Token (uMINT) | Money-market fund | Not US persons (distributor onboards) | $1,000 | Does not say (onboards institutions) | A single key | Fund redemption at NAV |
| USDM1 (Republic of the Marshall Islands tokenized secured bonds, redeemable at one US dollar) | Note | Not US persons (issuer onboards) | Not stated | Does not say (onboards qualified institutional counterparties and Marshallese citizens receiving ENRA basic income through the Lomalo wallet) | A single key | Issuer redemption |
| XAUt0 (Tether Gold on the USDT0 Network) | Commodity | Not US persons (no onboarding) | Not stated | Does not say | A 1-of-2 multisig | Redeem in kind |
| xStocks (tracker certificates by Backed Assets (JE) Limited, "x" tickers) | Note | Not US persons (issuer onboards) | $5,000 | Does not say (onboards individuals and entities) | A single key | Issuer redemption (and 2 other routes) |

The program name opens its Ketju file, where each term carries the issuer’s words, the document, and the date the words were found. The IRA reading is explained in [Tokenized assets in an IRA](/tokenized-assets/iras/).

## What the four groups mean

The files sort each program by the lowest investor status its issuer’s terms admit. When the words leave it unclear, the file takes the stricter reading.

**US retail investors.** The issuer admits US investors with no wealth test. That is a floor, not a promise of access. Onboarding still applies, the minimum still applies, and 33 of the 35 programs in this group publish no list of the states where they sell.

**US accredited investors.** The test is Rule 501(a) of Regulation D. A person qualifies with net worth over $1,000,000, alone or with a spouse or spousal equivalent, with the primary residence left out; or with income over $200,000 in each of the two most recent years, or $300,000 jointly, and a reasonable expectation of the same this year; or by holding a professional credential the SEC has designated. Certain trusts qualify with more than $5,000,000 in assets, and an entity qualifies when all of its equity owners are accredited.[^1] Offerings under Rule 506(c) may advertise, and in return “The issuer shall take reasonable steps to verify” that every buyer is accredited, so a checked box is not enough.[^2]

**US qualified purchasers.** A higher bar, set by the Investment Company Act: a natural person who owns at least $5,000,000 in investments, certain family companies with the same, or anyone who invests at least $25,000,000 on a discretionary basis for itself or other qualified purchasers.[^3] Private funds use it because section 3(c)(7) keeps a fund outside the Act only while its securities are “owned exclusively by persons who, at the time of acquisition of such securities, are qualified purchasers.”[^4] The fund cannot waive the test for a good client; the exemption depends on it. [BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I)](https://ketjuresearch.com/register/files/blackrock-buidl/) sits in this group, at a $5 million minimum.

**Not offered to US persons.** These programs sell only outside the United States, most under Regulation S. Its definition of a US person reaches past residence: it includes “any trust of which any trustee is a U.S. person” and any non-discretionary account “held by a dealer or other fiduciary for the benefit or account of a U.S. person.”[^5] Wealth does not change the answer. An advisor who finds one of these tokens in a US client’s wallet is looking at a holding the issuer’s terms do not allow.

## What a transfer allowlist means

An allowlist is a list of wallet addresses that the issuer or its transfer agent keeps. The token contract checks it on every transfer and refuses to move tokens to an address that is not on it. A wallet gets on the list only after onboarding: identity checks, the investor-status test, and signed fund documents. The list is how an issuer enforces the floor in the table. Superstate’s transfer-agency agreement with Exodus, filed with the SEC, states the rule in one sentence: “Superstate shall create, update, and maintain an Allowlist, and ensure that the smart contract(s) underlying the Tokenized Shares is/are programmed such that Tokenized Shares may only be transferred to or held by digital wallet addresses of persons or decentralized exchange pools on the Allowlist.”[^6]

Two things follow. First, buying the token from another holder does not make the buyer eligible. BlackRock’s documents for its BRSRV fund say: “Before transferring OnChain Shares, you (as the transferor) and the potential transferee must each have an active, permissioned (i.e., “whitelisted”) wallet registered with the Transfer Agent.”[^7] Second, the wallet is part of the eligibility, not just the investor. Fidelity says of its FDIT fund: “Only wallets that are approved by the transfer agent are authorized to purchase, redeem and hold OnChain class shares of the fund. Investors may not hold their shares in any other wallet.”[^8] For a client’s IRA, the wallet on the list has to be one the IRA’s custodian controls.

Of the 89 programs with a readable contract, **47 gate who may hold on at least one chain.** 31 put no allowlist on any contract read, including 15 of the programs closed to US persons, which is how their tokens can reach a US wallet at all. A token that moves freely is not a token anyone may own. PAX Gold is the plainest case: anyone may hold PAXG on chain, but “Only verified Customers may purchase PAXG from us or convert or redeem PAXG from us.”[^9] A holder who is not a Paxos customer can sell PAXG; it cannot redeem it with Paxos.

## Reading the other columns

**Minimum** is the first purchase the issuer’s terms state, in dollars. “Not stated” means the documents read give none. When the figure differs by chain or share class, the file’s notes give each one.

**IRAs and other accounts** reads the issuer’s documents for retirement accounts: they name IRAs as eligible, exclude them in writing, or do not say. The words in parentheses are the account types the issuer onboards, when its terms list them. Silence is not permission; [the IRA page](/tokenized-assets/iras/) explains why.

**Freeze key** names the weakest key that can freeze a holder, pause transfers, or claw tokens back, or that holds the admin key that grants those powers. Ketju reads it from the deployed contracts. In 53 of the 89 programs with a readable contract, that key is a single private key. A power is the issuer’s ability, not proof it has been used; it is also how an issuer obeys a court order.

**Exit** is the first route the file records. Many programs have more, and some routes are open only to the issuer’s own customers.

## What to check before a client buys

- The client, or the client’s account, meets the floor in the issuer’s current documents, and the issuer verified it.
- The program is offered in the client’s state, when the file says the issuer has not published a list.
- The minimum for the chain and share class the client will use.
- What the documents say about the account type: IRA, trust, or entity.
- The wallet the issuer will allowlist, and who holds its key.
- Who holds the freeze key, and what the issuer’s terms say about when it is used.
- How the client exits, and whether that route is open to the client or only to the issuer’s customers.

Ketju keeps each program’s [eligibility file](https://ketjuresearch.com/register/files/) current, quotes the issuer for every term, and reads the keys from the chain. For the account-type question in depth, read [Tokenized assets in an IRA](/tokenized-assets/iras/); for what the holder owns, read [Tokenized assets for RIAs](/tokenized-assets/).

## Sources

[^1]: [17 CFR 230.501(a), Regulation D: accredited investor](https://www.law.cornell.edu/cfr/text/17/230.501), Code of Federal Regulations (Legal Information Institute, Cornell Law School)
[^2]: [17 CFR 230.506(c), offerings with general solicitation: verification of accredited status](https://www.law.cornell.edu/cfr/text/17/230.506), Code of Federal Regulations (Legal Information Institute, Cornell Law School)
[^3]: [Investment Company Act section 2(a)(51), 15 U.S.C. 80a-2(a)(51): qualified purchaser](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section80a-2&num=0&edition=prelim), Office of the Law Revision Counsel, U.S. House of Representatives
[^4]: [Investment Company Act section 3(c)(7), 15 U.S.C. 80a-3(c)(7)](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section80a-3&num=0&edition=prelim), Office of the Law Revision Counsel, U.S. House of Representatives
[^5]: [17 CFR 230.902(k), Regulation S: definition of U.S. person](https://www.law.cornell.edu/cfr/text/17/230.902), Code of Federal Regulations (Legal Information Institute, Cornell Law School)
[^6]: [SEC EDGAR: Exodus Movement 10-K Ex. 10.7, Digital Transfer Agency Agreement (2025-08-08)](https://www.sec.gov/Archives/edgar/data/1821534/000182153426000009/digitaltransferagencyagree.htm), Quoted in Ketju’s file for Superstate Opening Bell (tokenized common stock of listed companies)
[^7]: [SEC EDGAR: BlackRock Funds Form N-1A post-effective amendment (485BPOS), prospectus and SAI for BlackRock Daily Reinvestment Stablecoin Reserve Vehicle, effective 31 July 2026](https://www.sec.gov/Archives/edgar/data/844779/000119312526327203/d283147d485bpos.htm), Quoted in Ketju’s file for BlackRock Daily Reinvestment Stablecoin Reserve Vehicle (RSVXX), BRSRV token
[^8]: [SEC EDGAR: Fidelity Hereford Street Trust 485BPOS, OnChain class prospectus and SAI dated 29 June 2026](https://www.sec.gov/Archives/edgar/data/917286/000091728626000089/filing12087.htm), Quoted in Ketju’s file for Fidelity Treasury Digital Fund, OnChain class (FYOXX), FDIT token
[^9]: [Paxos: PAX Gold Terms and Conditions (last modified December 12, 2025)](https://www.paxos.com/terms-and-conditions/pax-gold-terms-conditions), Quoted in Ketju’s file for PAX Gold (PAXG)

---

Published by Ketju Research (https://ketjuresearch.com). Educational analysis only; not legal, tax, compliance, or investment advice.
Machine-readable index: https://riadefi.com/llms.txt · Content API: https://riadefi.com/content.json